Sector reference · housing providers
ESG reporting for housing providers: the sector standard, and the law around it
ESG reporting for housing providers runs on a voluntary sector standard, the Sustainability Reporting Standard for Social Housing, now in version 2.1.
It is not UK SRS, which is a different standard with a different owner and the same initials.
Whether any reporting is a legal duty depends on the provider’s legal form and size, and this page sorts the duties by both.
The sector standard
The Sustainability Reporting Standard for Social Housing, in its own terms
The Sustainability Reporting Standard for Social Housing is an ESG reporting standard created by and for the housing sector.
It was established in 2020, and Sustainability for Housing, which owns and maintains it, was set up in 2021.
The standard is open-source and free to report against, and only formal Adopters pay an annual contribution, according to SfH’s 2026 Annual Review.
Version 2.1 was released on 13 April 2026 and replaces version 2.0, which had been in use since 2023.
SfH has asked Adopters to report against v2.1 from the October 2026 reporting cycle.
Its guidance for v2.1 describes the approach as comply or explain: where a provider cannot yet report a criterion, it leaves the response blank and says in its public ESG report when it expects to.
That is the sector’s own use of the phrase, and it carries no legal consequence, unlike the FCA’s comply-or-explain rules for listed companies.
The 2026 Annual Review covers 104 Adopters managing over two million homes, from the 2024/25 dataset, which was reported against v2.0.
| Point | Position |
|---|---|
| Owner | Sustainability for Housing, a company limited by guarantee run by a voluntary board |
| Established | Standard 2020; SfH 2021 |
| Status | Voluntary, sector-led |
| Cost to use | Free; formal Adopters make an annual contribution scaled by size |
| Version | v2.1, 13 April 2026, replacing v2.0 (in use since 2023) |
| Shape | 8 themes, an Adopter Profile, core and enhanced criteria |
| Approach | Comply or explain, in SfH’s words |
Same initials
The SRS and UK SRS are different standards
A search for “SRS” finds both.
They have no common owner, no common text and no legal link.
| UK SRS S1 and S2 | SRS for Social Housing | |
|---|---|---|
| Owner | Secretary of State for Business and Trade | Sustainability for Housing |
| Built from | IFRS S1 and S2, the ISSB standards | Criteria developed with the sector, its lenders and investors |
| Who uses it | Any UK entity; listed companies in five categories on comply or explain from 2027 | Housing providers that choose to adopt it |
| Materiality | Financial: what could influence investors and lenders | ESG criteria set for the sector, including impacts on residents |
| Current version | Published 25 February 2026 | v2.1, 13 April 2026 |
| Legal force | None of its own; comply or explain through the FCA’s listing rules | None |
Write the full name of each whenever both are in view: “UK SRS” for the national standards, and “the Sustainability Reporting Standard for Social Housing” for the sector one.
The national standards are read paragraph by paragraph on UK SRS S1 and UK SRS S2, which are built from the ISSB’s IFRS S1 and S2.
SfH says its standard keeps up to date with emerging frameworks such as UK SRS S1 and S2, and it responded to the government’s UK SRS consultation in September 2025.
The criteria
What the SRS asks a housing provider to report
The environmental criteria are the most numerical. These are a selection, by criterion number, from SfH’s v2.1 guidance.
| Criterion | What is reported | Enhanced (optional) |
|---|---|---|
| C1 | Distribution of EPC ratings of existing homes, at the financial year-end | Average SAP rating; energy use intensity in kWh/m²/yr |
| C2 | Distribution of EPC ratings of new homes completed in the year | Average SAP rating of new homes |
| C3 | Whether there is a net zero target and strategy, and the target date | Whether it is SBTi-aligned; whether there is a costed transition plan |
| C4 | Progress towards net zero, and retrofit activity in the last 12 months | Homes retrofitted, as a number and a share of what remains |
| C5 | Scope 1, 2 and 3 emissions, and total emissions per home | Whether the provider qualifies for SECR; the SECR intensity ratio |
| C6–C8 | Whether flood, water-stress and overheating risks to homes have been mapped and assessed in the last two years | Other physical risks; transition risks |
The guidance asks for Scope 3 by the fifteen categories of the GHG Protocol, rather than as one total, so that confidence in each category can be stated.
It names purchased goods and services, capital goods, use of sold products and downstream leased assets as the categories likely to matter most for a housing provider, following the GHG Protocol.
It asks landlords to report regulated emissions from their homes, the fabric and heating they control, rather than residents’ plug-in use.
The climate-risk criteria ask about physical risks to the housing stock: flooding, water stress, overheating and, in the enhanced criteria, wildfire and storms.
Version 2.1 also aligned the damp and mould criteria with Awaab’s Law and added a tab mapping the STAIR and ARC reporting requirements to the standard.
Three governance criteria that rarely change, such as the code of governance followed, moved into a new Adopter Profile at the start of the report.
The law
Which reporting duties reach a housing provider, by legal form
No statute imposes an ESG reporting duty on housing providers as a class.
What reaches a provider is decided first by its legal form, then by its size, and then by what it has listed.
A registered society is a body corporate under section 3 of the Co-operative and Community Benefit Societies Act 2014, but it is not a company, so the Companies Act reporting duties do not reach it as such.
A provider that is a company is in SECR if it exceeds at least two of £36 million turnover, £18 million balance sheet and 250 employees, under Schedule 7 paragraph 20B.
ESOS reaches any undertaking that is large under Schedule 1 to the ESOS Regulations, and a registered society is an undertaking because it is a body corporate.
Public bodies are excluded from ESOS by regulation 16; whether a particular provider counts as one is a legal test, and worth checking rather than assuming in either direction.
The climate duty in section 414CA reaches only companies with more than 500 employees in its categories, and a company with listed bonds can be one, because a traded company is one with any transferable securities on a UK regulated market.
The FCA’s UK SRS rules do not reach bonds: debt and debt-like securities in UKLR 17 are excluded by PS26/19 ¶3.7.
How the FCA’s rules work for the companies they do reach is on the FCA and UK SRS.
Housing provider duty check
1 reporting duty reaches you on these answers.
- SECRNot this routeSECR is written into the Companies Act directors’ report. A registered society is a body corporate but not a company, so Schedule 7 does not reach it as such; check the accounting requirements that bind you.SI 2008/410 Sch 7; CCBS Act 2014 s.3
- ESOSIn scopeA large undertaking on these figures — a registered society is a body corporate, so it is an undertaking. Qualification is judged on 31 December 2026; notification by 5 December 2027. Whether a provider is a "public body" is a legal test worth checking, not assuming.SI 2014/1643 Sch 1 ¶¶1, 1A; regs 4, 15, 16
- Climate-related financial disclosureNot this routeThe strategic report duty is a Companies Act duty and does not reach this legal form.CA 2006 s.414CA
- FCA listing rulesExcludedDebt and debt-like securities are listed under UKLR 17, which the final rules exclude. A bond issuer is not required to report against UK SRS by them.FCA PS26/19 ¶3.7
- Regulator of Social HousingStandards applyThe consumer standards apply to registered providers in England. They set outcomes on safety and quality, transparency, neighbourhood and tenancy; they are not a sustainability reporting standard.RSH Consumer standards Code of Practice, 1 April 2024
- Sustainability Reporting Standard for Social HousingVoluntaryThe sector-led ESG standard, v2.1, used in the October 2026 reporting cycle. Free to use; formal Adopters make an annual contribution.Sustainability for Housing, SRS v2.1 guidance
- UK SRS S1 and S2VoluntaryAvailable for voluntary use by any entity. No requirement or threshold for unlisted bodies has been proposed.DBT, UK SRS guidance, 25 February 2026
Indicative, not advice.
It reads one set of figures for one entity; group structures, public-body status and the two-year rules need the provisions themselves.
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Wording
The SECR test for a housing company, word for word
A landlord’s homes sit on its balance sheet, so the balance-sheet limb is the one to check first.
The test is written as an exemption: a company is exempt if it meets two or more of the “not more than” conditions.
So the figures are thresholds to be exceeded, and a provider with exactly £36 million of turnover is not over that limb.
Guidance written for the sector sometimes says “£36m or more”; where wording differs, the Schedule governs.
A change of side takes effect only once it has held for two consecutive years.
The SRS asks in its enhanced criterion C5E whether a provider qualifies for SECR, and for the SECR intensity ratio if it does, so the two sit side by side in a provider’s report.
The provision-level reading, including LLPs and groups, is on SECR thresholds.
| Limb | Statutory wording | A provider exactly at the figure |
|---|---|---|
| Turnover | Not more than £36m (exempt side) | Not over the limb |
| Balance sheet total | Not more than £18m | Not over the limb |
| Employees | Not more than 250 | Not over the limb |
The regulator
The Regulator of Social Housing and the 2023 Act
The Social Housing (Regulation) Act 2023 reformed the consumer regulation of social housing in England.
The Regulator of Social Housing’s consumer standards apply from 1 April 2024, and its Code of Practice sets out what the Regulator looks for when it seeks evidence that a provider delivers their outcomes.
There are four: safety and quality; transparency, influence and accountability; neighbourhood and community; and tenancy.
None of them is a sustainability reporting standard, and none requires an ESG report.
They overlap with the SRS in subject matter — the quality and safety of homes, and damp and mould in particular — which is why SfH aligned those criteria in v2.1.
Treat the two as separate obligations with separate audiences: the Regulator’s standards are binding outcomes, and the SRS is a voluntary disclosure.
| Consumer standard | Applies from |
|---|---|
| Safety and quality | 1 April 2024 |
| Transparency, influence and accountability | 1 April 2024 |
| Neighbourhood and community | 1 April 2024 |
| Tenancy | 1 April 2024 |
Using both
Where the SRS data meets UK SRS, if a provider uses both
A provider that chooses to report against UK SRS S2 as well can reuse much of its SRS data.
This table is our reading of where the two meet; it is not a mapping published by either owner.
| SRS criterion | Where it would sit under UK SRS S2 | What UK SRS adds |
|---|---|---|
| C5 — Scope 1, 2 and 3 | Metrics and targets | Gross emissions measured to the GHG Protocol, with any net target beside them |
| C3 — net zero target and strategy | Metrics and targets; strategy | The target’s basis, and progress against it |
| C3E — costed transition plan | Strategy | How the plan affects the business model and finances |
| C6–C8 — flood, water and overheating risk | Strategy; risk management | The financial effect on the entity, over stated time horizons |
| C4 — retrofit progress | Strategy; metrics | Capital allocated to the transition |
| Governance criteria | Governance | Board oversight of climate-related risks and opportunities specifically |
The biggest difference is the question each asks.
UK SRS asks what could affect the entity’s cash flows, access to finance and cost of capital, in the four-pillar shape of the TCFD recommendations.
The SRS asks a wider set of ESG questions set for the sector, including how the provider’s homes affect the people who live in them.
SfH’s own expectation, in its September 2025 consultation response, was that housing associations are unlikely to face UK SRS requirements themselves, but will be asked for more ESG information by funders who do.
UK SRS stays voluntary for any provider whose shares are not listed in the five categories.
Dates
The dates that matter to a housing provider
The sector standard runs on its own cycle, with v2.1 reporting from October 2026.
The statutory dates come from the regimes a provider is actually in: ESOS for a large provider of any form, SECR for a large provider that is a company.
The FCA’s final rules apply from accounting periods beginning on or after 1 January 2027, and only to issuers in the five listing categories.
No requirement for unlisted bodies to use UK SRS has been proposed, and the modernising corporate reporting consultation, which closes on 30 November 2026, does not propose one.
The wider set of UK duties is set out on the sustainability reporting primer.
- 2020Sustainability Reporting Standard for Social Housing established
- 2023SRS v2.0 in use
- 1 Apr 2024RSH consumer standards apply
- 25 Feb 2026UK SRS S1 and S2 published
Voluntary.
- 13 Apr 2026SRS v2.1 released
- 30 Sep 2026FCA final rules, PS26/19
Bonds excluded.
- Oct 2026First reporting cycle on v2.1
- 30 Nov 2026Modernising corporate reporting consultation closes
- 31 Dec 2026ESOS Phase 4 qualification date
- 5 Dec 2027ESOS Phase 4 notification due
In practice
Running the SRS beside the statutory duties
One data set
Collect energy once
The kWh behind an ESOS assessment, the SECR figures and the SRS Scope 1 and 2 criteria are the same measurements.
Collect them once, for the whole boundary.
Boundaries
Say what is counted
The SRS counts homes the provider controls the energy standards of.
SECR counts energy the company is responsible for.
State each boundary where you report.
Modelled data
Label estimates
The v2.1 guidance accepts modelled EPC and energy data if disclosed as such.
A statutory report needs the same honesty about its methodology.
Assurance
Optional everywhere
No regime here requires assurance.
SfH reports that many housing associations seek it voluntarily for their sustainability data.
If you want to check where your organisation sits, a free 15-minute call can be booked on the booking page.
Frequently asked
Social housing ESG reporting: questions people ask
What is the Sustainability Reporting Standard for Social Housing?
It is a voluntary, sector-led ESG reporting standard for housing providers, owned by Sustainability for Housing, a not-for-profit company limited by guarantee.
The standard was established in 2020.
The current version, v2.1, was released on 13 April 2026 and is used from the October 2026 reporting cycle. It is free to download and report against.
Is the social housing SRS the same as UK SRS?
No. They share initials and nothing else.
UK SRS S1 and S2 are the UK Sustainability Reporting Standards published by the Department for Business and Trade on 25 February 2026.
The Sustainability Reporting Standard for Social Housing is a separate, voluntary sector standard with its own owner, criteria and reporting cycle.
Is ESG reporting mandatory for housing associations?
There is no ESG reporting duty for housing providers as such.
Which statutory regimes apply depends on legal form and size: a large company can be in SECR, any large undertaking — a registered society included — can be in ESOS, and a company with more than 500 employees in the s.414CA categories makes climate-related financial disclosures.
The sector standard and UK SRS are voluntary.
Do the FCA’s UK SRS rules apply to housing associations with listed bonds?
Not through the listing of bonds.
The FCA’s final rules (PS26/19) apply to listed companies in UKLR 6, 14, 15, 16 and 22, and exclude debt and debt-like securities in UKLR 17.
A housing provider whose only listed securities are bonds is not required by those rules to report against UK SRS.
What changed in SRS v2.1?
Sustainability for Housing cut the themes from 12 to 8, moved three governance criteria that rarely change into a new Adopter Profile, split multi-part criteria, added worked examples, aligned the damp and mould criteria with Awaab’s Law, added a tab mapping STAIR and ARC requirements, and added optional explanatory fields. v2.0 had been in use since 2023.
How many housing providers report against the SRS?
Sustainability for Housing’s 2026 Annual Review covers 104 Adopters managing over two million homes, based on the 2024/25 dataset.
In September 2025 SfH described the standard as having over 130 housing association adopters committed to reporting each year.
The two figures measure different things: the dataset and the commitments.
Does SECR apply to a housing association?
Only if it is a company or LLP. SECR sits in the Companies Act directors’ report, so a housing association that is a company and is over two of the three limbs — turnover more than £36 million, balance sheet more than £18 million, more than 250 employees — reports its energy and carbon there.
A registered society is not reached through that route.
What does the Regulator of Social Housing require on sustainability?
The Regulator’s consumer standards, in force from 1 April 2024, set outcomes on safety and quality; transparency, influence and accountability; neighbourhood and community; and tenancy.
They are not a sustainability reporting standard, and this page does not treat them as one.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Sustainability for HousingUpdating the Guidance on the SRS — Guidance for Version 2.1, Spring 2026 (PDF)
v2.1 replaces v2.0; themes cut from 12 to 8; the criteria quoted on this page; the comply-or-explain approach.
- Sustainability for HousingSustainability Reporting Standard updated to support evolving sector needs (13 April 2026)
The v2.1 release and the October 2026 reporting cycle.
- Sustainability for HousingThe Sustainability Reporting Standard for Social Housing — Annual Review 2026 (PDF)
104 Adopters, over two million homes, the 2024/25 dataset.
- Sustainability for HousingSfH responses to the UK SRS and assurance-oversight consultations (18 September 2025)
SfH’s own view of how UK SRS will reach housing providers through their funders.
- Sustainability for HousingThe SRS — Adopter hub
The standard’s home; the learning hub is for Adopters.
- Regulator of Social HousingConsumer standards Code of Practice
Applies from 1 April 2024: safety and quality; transparency, influence and accountability; neighbourhood and community; tenancy.
- legislation.gov.ukSocial Housing (Regulation) Act 2023 (c. 36)
The Act that reformed consumer regulation of social housing in England.
- legislation.gov.ukCo-operative and Community Benefit Societies Act 2014, section 3
A registered society is a body corporate.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
UK SRS is available for voluntary use by any entity.
- Department for Business and TradeUK SRS S1 and UK SRS S2
Published 25 February 2026.
- Financial Conduct AuthorityPS26/19 — Aligning listed issuers’ sustainability disclosures with international standards
Comply or explain for UKLR 6, 14, 15, 16 and 22 from 2027.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶3.6–3.7
Debt and debt-like securities (UKLR 17) are excluded.
- legislation.gov.ukSI 2008/410, Schedule 7, ¶¶20B and 20D
The SECR exemption test and the 40,000 kWh de minimis.
- legislation.gov.ukESOS Regulations 2014, Schedule 1
The large-undertaking test.
- legislation.gov.ukESOS Regulations 2014, regulation 16
Public bodies are not relevant undertakings.
- legislation.gov.ukCompanies Act 2006, section 414CA
Who makes climate-related financial disclosures.
- legislation.gov.ukCompanies Act 2006, section 474(1) — “traded company”
Any transferable securities admitted to trading on a UK regulated market.
- IFRS FoundationIFRS Sustainability Disclosure Standards Navigator
The ISSB standards UK SRS is built from.
- TCFDTCFD recommendations
The four-pillar climate structure.
- GHG ProtocolCorporate Accounting and Reporting Standard
Scopes 1, 2 and 3, which the SRS asks for.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation
Open until 30 November 2026; proposes no UK SRS requirement for unlisted bodies.
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